AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Trustees of the Yogi Bhajan Administrative Trust sought to collect attorney fees after a judgment for $718,720.63 was entered in their favor in 2014 against Inderjit Kaur Puri (Bibiji). Despite partial satisfaction of the judgment through garnishment in 2017, Bibiji had not paid any of the remaining attorney fees. The Trustees attempted to discover Bibiji's financial ability to pay by filing a request for a debtor’s examination and subpoenaing documents. Bibiji moved to quash the subpoena and for a protective order, arguing improper service and privilege concerns. The district court ordered Bibiji to produce certain documents, leading to Bibiji's appeal.

Procedural History

• Khalsa v. Puri, 2015-NMCA-027: Affirmed the district court's order for Bibiji to pay the Trustees’ attorney fees and costs.
• Khalsa v. Puri, No. 33,622, mem. op.: Affirmed the award of attorney fees in a separate opinion.
• Khalsa v. Puri, A-1-CA-36701, mem. op.: Affirmed the priority of the Trustees' garnishment to partially satisfy the attorney fees judgment.

Parties' Submissions

• Plaintiffs-Appellees (Trustees): Argued that the subpoena was properly served on Bibiji’s attorney, the district court had authority to order discovery in aid of enforcement of a judgment, and the documents requested were not privileged.
• Defendant-Appellant (Bibiji): Contended that the subpoena was improperly served, making it invalid; the district court lacked authority to order discovery due to improper service; privileged documents were improperly ordered to be produced; and the sanctions award was an abuse of discretion and violated due process.

Legal Issues

• Whether the subpoena served on Bibiji’s attorney was valid.
• Whether the district court had authority to order discovery in aid of enforcement of a judgment.
• Whether the district court erred by ordering Bibiji to produce privileged documents.
• Whether the district court’s sanctions award constituted an abuse of discretion and violated due process.

Disposition

• The Court of Appeals affirmed the district court's order granting the Trustees' motion for sanctions based on Bibiji's failure to comply with the court order to produce documents.

Reasons

• The Court of Appeals, per Bogardus, J., with Baca, J., and Bustamante, J., concurring, held that:
  Service of the subpoena on Bibiji’s attorney was effective and valid under the rules of civil procedure, supporting the district court's discovery order (paras 4-14).
  Bibiji's failure to comply with the discovery order was not substantially justified, and the district court did not abuse its discretion in entering the discovery order or in its sanctions award (paras 15-18, 24-35).
  Bibiji waived any privilege against disclosing her federal tax returns by placing her tax liability at issue in the litigation (paras 20-22).
  The sanctions imposed by the district court did not violate due process, as Bibiji and her attorney were given notice and an opportunity to defend against the sanctions, and the sanction amount was not deemed excessive given the circumstances (paras 36-40).